Data Privacy by Design
Architecting privacy into your health application
Privacy in healthcare is both a legal requirement and a competitive advantage. Privacy by Design means building privacy controls into your architecture from the start.
Data Minimization Principles
Collect only what you need, retain only what you must:
- Purpose specification: Define exactly why each data point is collected
- Collection limitation: Only collect data that serves a specified purpose
- Data retention: Define and enforce retention schedules for each data type
- Anonymization: Anonymize data when the purpose doesn’t require identification
Consent Management Architecture
Consent management is a core architectural component, not an afterthought:
- Granular consent: Separate consent for treatment, payment, operations, and research
- Consent lifecycle: Capture, store, enforce, audit, revoke
- Temporal consent: Time-limited consent with automatic expiration
- Emergency override: Mechanisms for emergency access with audit trail
- Minor consent: Special handling for pediatric data
De-Identification Techniques
Cross-Border Data Transfer
Health data crosses borders with increasing frequency:
- EU-US Data Privacy Framework: New framework for EU-US data transfers
- Standard Contractual Clauses (SCCs) : EU-approved contract terms for data transfers
- Binding Corporate Rules (BCRs) : Internal data protection policies for multinational organizations
- Data residency: Some countries require health data to remain within national borders
Privacy Impact Assessments
A DPIA (Data Protection Impact Assessment) is required under GDPR for high-risk processing:
- Describe the processing and purpose
- Assess necessity and proportionality
- Identify and assess risks to individuals
- Identify measures to mitigate risks
- Document the decision